State and Federal Source Water 

Assessment and Protection

Program Measures– Final 

Reporting Guidance
Disclaimer

This document is not a regulation. Thus, it cannot impose legally-binding requirements on EPA,

states, Territories, authorized Tribes, or the public. To the extent this document summarizes

statutory or regulatory requirements, and anything in that summary is in conflict with the statutes

or regulations, the statutes and regulations control. This Guidance document does not change

or substitute for those legal requirements, is not itself legally binding, and does not confer legal

rights or legal obligations upon any member of the public, EPA, states, or any other agency. In

following this Final Reporting Guidance, EPA decision makers retain the discretion to adopt

approaches on a case-by-case basis that differ from it where appropriate. As necessary and

appropriate, EPA may change this Reporting Guidance in the future.

Office of Water (4606)

EPA-816-R-05-001

www.epa.gov/safewater

March, 2005 Printed on Recycled Paper
Table of Contents

Part A. Introduction ......................................................... 1

1. Purpose of Final Guidance .............................................. 1

2. How This Document is Organized ......................................... 2

3. Background, EPA 2003-2008 Strategic Plan, and National Water Program Guidance for

Fiscal Year 2005 and forthcoming National Water Program Guidance for Fiscal Year

2006 ............................................................... 2

4. National Source Water Assessment and Protection Program Measures and Other

Information in this Guidance ............................................. 3

5. Framework Serving as the Basis for the State and National Source Water Assessment

and Protection Measures and Other Information .............................. 5

6. Rationale for How the Measures and Other Information are Indicators to Help Answer the

Key National Questions ................................................. 8

Part B. Summary of National and State Source Water Measures and Information ......... 13

Question 1: Are the State Source Water Assessments Being Completed Under Section

1453 of the SDWA? .................................................. 14

Question 2: What Threats to Sources of Drinking Water Are Being Found in Assessment

Results? ........................................................... 18

Question 3: How Are Current and Future Drinking Water Supplies Being Protected? ... 20

Question 4: Are Source Water Protection Actions Making a Difference to Public Health

Protection? ......................................................... 26

Part C. Integrated Structure and Framework for Source Water Measures and Information

Reporting ............................................................. 29

Appendix I–Issues and Answers Raised on the Initial Reporting Guidance of 2003 ........ 31

Appendix II–Crosswalk of National Questions, Measures, and Information Elements ...... 39

Appendix III–Representations of Reporting Spreadsheets ........................... 40

Appendix IV–Definition of Substantial Implementation of a SWP Strategy ............... 49

Appendix V–Acronyms ...................................................... 50

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Part A. Introduction

1. Purpose of Final Guidance

Over 270 million Americans receive drinking water from approximately 161,000 public water

supplies. Americans enjoy some of the world's safest drinking water. Nonetheless, drinking

water safety cannot be taken for granted. For instance, drinking water that is not adequately

treated or that travels through an inadequate distribution system can endanger the health of a

community. However, in many cases, public health protection starts at the drinking water

source. A community is likely to be at higher risk if it relies on a source that is contaminated.

Preventing contamination of drinking water sources depends on the awareness,

participation and actions of Federal agencies, state agencies, local governments, interest

groups, individual citizens and the business community. Indeed, source water protection is

based on the premise that no single entity can effectively be the driver of drinking water source

protection efforts in every case. We all need to work together. Source water includes all

current sources of drinking water from ground waters and surface waters. However, as the

results of source water assessments are used to launch source water protection programs,

such programs should not be deterred from comprehensive efforts to protect surface and

ground waters that are not now used for drinking water.

Source water protection should be a standard part of providing safe drinking water to the

public. If not eliminated, risks to source waters should be reduced to minimize risks to public

health. Building consensus to do this requires a long and sustained effort.

Source water protection means different things in different situations. This is appropriate

because the threats to drinking water sources and the means to address those threats are site

specific and most effectively implemented at the local level, with assistance from other

government and private stakeholders.

The Safe Drinking Water Act (SDWA), amended in 1996, promotes a multiple-barrier

approach to safeguarding the nation's water supply. This multiple-barrier approach goes

beyond the traditional emphasis on treatment to address new challenges and reflects a better

understanding of the need for a coordinated source water protection effort. The multiple-barrier

approach encompasses delineation and prevention of contamination of drinking water sources,

treatment appropriate to the quality of the source water, well-engineered distribution and

storage systems, operator training and certification and an informed and involved public. 

Preventing contamination, therefore, is one of the key elements of the multiple-barrier approach.

The purpose of this guidance is to promote coordinated efforts that should drive state and

Federal actions to assist localities, implement protection actions where a state or Federal

program has a specific responsibility, establish tangible measures of state and local source

water assessment results and protection actions and institutionalize practical information

sharing systems so states and Federal agencies can communicate results and the status of the

program. By doing so, EPA and its many partners can more effectively and efficiently maintain

and improve the quality of America's drinking water.
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2. How This Document is Organized

Part A, this introduction, includes four remaining sections: (1) background on the

development of this final reporting guidance and a description of the EPA Strategic Plan; (2) the

source water assessment and protection measures in the "National Water Program Guidance

for FY 2005 and FY 2006;" (3) the framework that serves as the basis for the state and national

source water assessment and protection measures, and other information; and (4) the rationale

for how the measures and other information will answer key national questions for the source

water assessment and protection program.

Part B includes the information associated with each measure or information element, a

description of how the information should be reported in the spreadsheet format, and the

definitions for the concepts in the measure and information quality guidelines.

Part C describes reporting options, including using spreadsheets or providing information to

EPA through a source water module reporting framework.

Finally, there are five Appendices: I - Issues and answers raised on the initial 2003 reporting

guidance; II - Crosswalk of the national questions, measures and information elements;

III - Reporting tables as a proxy for the spreadsheets that states and regions should use to

report the measures and other information; IV - The definition of substantial implementation of a

source water protection strategy; and V - Acronyms used in this Guidance.

3. Background, EPA 2003-2008 Strategic Plan, and National Water Program

Guidance for Fiscal Year 2005 and forthcoming National Water Program Guidance

for Fiscal Year 2006

Early in 2000, EPA's regional Drinking Water and Underground Injection Control (UIC)

Branch Chiefs, the Ground Water Protection Council (GWPC) and the Association of State

Drinking Water Administrators (ASDWA) articulated and discussed the need for a clear vision,

goals and measures for the Source Water Program. From 2000 through early 2003, EPA held

meetings with state organizations, one public stakeholder meeting and numerous internal EPA

meetings. In 2002 and 2003, the Agency worked on a new Strategic Plan.

In March and April 2003, EPA met with states at the ASDWA and GWPC Spring meetings,

and all states were provided a review of draft reporting guidances for the Source Water

Assessment and Protection and Underground Injection Control Programs. At the same time,

EPA met with these state-level organizations to ensure consistency between the measures and

other information in the draft guidances and those measures in the draft Agency Strategic Plan

and related documents. The state/EPA workgroups met in early May 2003 to discuss the

measures again. Subsequently, GWPC and ASDWA wrote to EPA supporting initiation of the

source water assessment and protection and underground injection reporting processes. EPA

then released the State and Federal Source Water Assessment and Protection Program

Measures - Initial Reporting Guidance in August 2003, and encouraged states to pilot test it in

the Fall of 2003.

The vision for the Source Water Assessment and Protection Program was set in Goal 2

(Clean and Safe Water) of EPA’s Strategic Plan, published in October 2003. The vision is

included under Objective 2.1 (Protect Human Health) and Sub-objective 2.1.1 (Water Safe To
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Drink), which reads, "By 2008, 95% of the population served by community water systems will

receive drinking water that meets all applicable health-based drinking water standards through

effective treatment and source water protection.” The key source water protection strategic

target under this sub-objective is that "by 2008, 50% of source water areas for community water

systems will achieve minimized risk to public health (minimized risk is achieved by substantial

implementation, as determined by the State, of source water protection actions in a source

water protection strategy)."

Measures supporting this strategic target were published in the National Water Program

Guidance for Fiscal Year 2005 and will be published in a forthcoming National Water Program

Guidance for Fiscal Year 2006. These measures, known as "Program Activity Measures”

(PAMs) will measure the aggregate results of source water assessments, state-wide, regionally

and nationally, and measure source water protection strategy implementation. The Source

Water Strategic Target and PAMs are:

State and Local Source Water Assessment and Protection 

Strategic Target and Program Activity Measures - National Water Program Guidance, FY 2006

Strategic Target F: Percentage of source water areas for community water systems that achieve minimized

risk to public health (minimized risk achieved by substantial implementation, as determined by a state, of

source water protection actions in a source water protection strategy).

PAM SDW-9

(FY 2006)

Percent of community water systems for which source water protection strategies are in

place and are being implemented (cumulative). (Formerly PAMs 10 and 11 combined)

PAM SDW-11

(FY 2006)

Identify at the State level the most prevalent and/or threatening categories of

existing/potential sources of contamination for surface and ground water for community water

systems (annually.) (Formerly PAM 15)

Notes:

Information on the associated population will also be requested for Strategic Target F and PAM SDW-9.

Information for PAM SDW-11 may not change after the first reporting year.

In 2004, EPA reconvened the source water measures workgroup and had several meetings

throughout the year and at the Spring and Fall meetings of ASDWA and GWPC. Comments

were received on a draft final reporting guidance subsequent to the Fall meetings. These

discussions and comments addressed refinements to the definition of substantial

implementation of source water protection strategies and issues from the initial reporting

guidance used during the pilot year of 2003. The discussions by the workgroup and at the

meetings are reflected in this final reporting guidance.

4. National Source Water Assessment and Protection Program Measures and

Other Information in this Guidance

In the course of discussions between stakeholders and EPA from 2000-2004, four key

questions were identified to guide development of the indicator measures and other information,

and provide a structure for subsequent analysis. They are:

1. Are the state source water assessments being completed under Section 1453 of the

SDWA?

2. What threats to sources of drinking water are being found in assessment results?
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3. How are current and future drinking water supplies being protected?

4. Are source water protection actions making a difference to public health protection?

This final guidance sets forth specific indicator measures and information elements,

consistent with the Agency's Strategic Plan and National Water Program Guidance, to provide

information to answer these questions and provide indications of whether Strategic Target F is

being attained. Below is a table showing the indicator measures and other information that will

be used to answer the national questions.

Summary of National and State 

Source Water Measures and Other Information for State and Local Actions

Question Source Water Measures and Other Information

1. Are the state source water

assessments being completed

under Section 1453 of the

SDWA?

1.1 Mapped source water areas (SWAs) for CWSs by state. 

(Other information)

1.2 PWSs with complete assessments, and associated

population served - cumulative. (Other information)

2. What threats to sources of

drinking water are being found in

assessment results?

2.1 For CWSs, most prevalent categories of significant

potential sources of contamination (aggregated at the state

level and nationally, using the assessment information, split by

ground water and surface water systems). (PAM SDW-11)

2.2 For CWSs, most threatening categories of significant

potential sources of contamination (aggregated at the state

level and nationally, using the assessment information, split by

ground water and surface water systems). (PAM SDW-11) 

3. How are current and future

drinking water supplies being

protected?

3.1 Percent of CWSs that have source water protection

strategies in place and are being implemented, and associated

population served - cumulative. (PAM SDW-9)

3.2 For CWSs, percentage of source water areas that have

source water protection strategies substantially implemented,

and associated population served - cumulative. (Strategic

Target F) 

3.3 State source water protection activities. (Other

information)

4. Are source water protection

actions making a difference to

public health protection?

4.1 Over time, percent change in CWSs or SWAs for CWSs,

and associated population served, with substantial

implementation of source water protection strategies (proxy for

minimized risk to public health). (Strategic Target F)

See Part B for definitions of the information elements.

In addition to the national and state measures for source water assessment and protection,

the National Water Program Guidance noted above includes national measures for Clean Water

Act (CWA) and SDWA integration. These measures and other information are the culmination

of internal efforts since 2001 to better integrate the program requirements and policies of the

two statutes to increase the focus on protection actions for sources of drinking water. These

measures and other information indicate that EPA is: (a) strengthening the Nationally

Recommended Water Quality Criteria (NRWQC) that are published under Section 304(a) of the

CWA by amending current criteria or publishing new criteria (FY 2005 PAMs 22 and 23); (b)
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assuring that state water quality standards support the public water supply use for contaminants

of concern originating in surface water from human activity (FY 2005 PAMs 21 and 24); and (c)

enlisting the CWA tools to address those state water quality standards (FY 2005 PAMs 25, 26

and 27). The latter three PAMs possibly will entail actions under the Nonpoint Source,

Stormwater and CWA permitting programs.

Complementing the integration measures and actions across the Water statutes, EPA's

Office of Water (OW) is continuing to work across other programs to coordinate efforts to protect

source waters. Coordination actions are occurring with: (a) the Office of Pesticide Programs

(OPP) to protect source water through registration procedures for pesticides; (b) the Office of

Underground Storage Tanks (OUST) to protect source water by focusing program resources on

tanks within state delineated source water areas; (c) the Office of Solid Waste (OSW) to identify

and better mitigate the effects of ground water plumes migrating off-site of contaminated sites in

delineated source water areas; (d) the Office of Science Coordination and Policy (OSCP) to

develop an endocrine disruptor screening program that includes drinking water contaminants;

and (e) the Office of Research and Development (ORD) to implement research on numerous

aspects of source water assessment and protection.

EPA is also continuing to coordinate actions with other Federal agencies and departments

to increase technical and policy support for source water protection activities. Such

coordination activities include, but are not limited to, working with: (a) the U.S. Department of

Agriculture (USDA) to facilitate use of Farm Bill resources; and (b) the Department of Interior's

U.S. Geological Survey (USGS) regarding its source water related monitoring programs and

other technical support activities.

5. Framework Serving as the Basis for the State and National Source Water

Assessment and Protection Measures and Other Information

The source water measures and other information at the state, regional and national levels

should provide guideposts for judging the progress of strategic actions to minimize risks to

source waters, as envisioned by the provisions of the SDWA Amendments of 1996. The source

water measures and information also provide information for targeting actions in source water

areas (SWAs) to prevent contamination from the most serious potential threats to drinking

water. State-wide, regional and national information regarding source water assessment results

and protection actions also provides accountability to legislative bodies (state legislatures and

Congress) and is a means to demonstrate that tax dollars are being well spent and that EPA is

meeting certain objectives and strategic targets under the EPA Strategic Plan. In addition, EPA

should be able to measure its own program outputs and whether they are leading toward

contamination prevention and minimized risk, and thereby should be able to provide feedback

and opportunities for national, regional, state and local program refinement and improvement.

A. Congress required assessments to be used at the state and Federal levels for

protection.

Congress provided the states with the lead responsibility for implementing source water

assessments under Section 1453 of the Safe Drinking Water Act (SDWA). Section 1453 of the

SDWA, as described in the Final National State Source Water Assessment and Protection

Programs guidance, published August 6, 1997:
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"requires states to develop, submit to EPA, and implement, once approved, SWAPs [Source

Water Assessment Programs]. These required state SWAPs...must meet all the

requirements under sections 1453 and 1428(b) and (c) of the SDWA Amendments of 1996."

Further, the Guidance pointed to the goal of the SWAP program in SDWA Section 1453 that

"[e]ach source water assessment needs to be, as stated in the statute, 'for the protection and

benefit of public water systems' [section 1453(a)(1)].” In other words, Congress clearly desired

that an assessment be a precursor to the development of a full source water protection program

to protect the drinking water for that area. (See below for more on Congress' intent that source

water assessments would lead to voluntary protection programs.)

B. Congress expected that voluntary protection actions would follow assessments,

even though they are not mandated, and that all the tools of state and Federal

governments could be brought to bear on implementing source water protection

programs based on the source water assessments.

Although the SDWA includes many provisions that indicate that source water protection is

voluntary, the clear intent in the SDWA is that the mandatory assessments will lead to voluntary

protection programs.

Indeed, House and Senate committee reports make this point. For example, House Report

104-632, Part 1 states "the Committee recognizes that [source water protection] can be a

cost-effective strategy for ensuring safe drinking water supplies...to address [source water

protection], the bill creates a new program in which states with primacy will conduct an

assessment, coordinated with existing information and programs, to determine the vulnerability

of sources of drinking water within state boundaries...designed to protect source water from

threats identified during the assessment."

The 1997 Guidance also states "while these [Source Water Protection and Petition

Programs] are voluntary, EPA believes it is wise for states to plan for protection programs at the

same time they plan for and implement their SWAPs. Such simultaneous planning would

provide both efficient use of taxpayers’ SWAP funds and accountability to the public regarding

productive use of source water assessment information." Also in the guidance is a statement

that "the new prevention provisions of the Amendments has two key elements: (1) a clear state

lead, with flexibility and resources to achieve results. This is necessary because prevention is

ultimately about land use and water quality management, which generally are exercised at the

state and local levels and (2) a strong ethic of public information and involvement within the

state's decision making processes."

The 1997 Guidance describes all the tools in the amended SDWA for states to use to

develop and implement source water protection programs. It reads: "in the 1996 Amendments

to the SDWA, Congress included a number of important provisions related to SWP beyond the

SWAPs including, (1) continuation of the Wellhead Protection Program (Section 1428), a new,

optional petition program (Section 1454)... and (3) and authority for states to use DWSRF funds

for source water protection programs [Sections 1452(g)(2)(b), and four subsections under

Section 1452 (k)(1)-(A)(i),(A) (ii), (A)(iii), (D)]."
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Finally, the 1997 Guidance included two chapters which fully described programs under the

SDWA as well as other Federal programs that can assist states and localities implementing

source water assessment and protection programs:

C Chapter Four describes the relationship between source water assessment and protection

and other Public Water Supply Supervision (PWSS) Program efforts, including SDWA

rulemaking efforts, Wellhead Protection and UIC.

C Chapter Five summarizes some of the programs outside of the SDWA, administered by EPA

and other Federal agencies, that states can build on in developing and coordinating their

source water programs. For example, it describes all of the tools under the Clean Water Act

using the Watershed Approach components of water quality standards, monitoring

programs, National Pollutant Discharge Elimination System (NPDES) Program, Nonpoint

Source Program, Total Maximum Daily Load (TMDL) Program, National Estuary Program,

Clean Lakes Program and the Wetlands Program. It also describes other EPA and Federal

programs, many of which are jointly administered with the states.

C. To utilize all of the state and Federal statutory authorities and tools to assist with

state and local protection efforts, one critical activity is for states to take the lead in

understanding the results of assessments, understand the status of source water

protection actions at the state and local levels, and provide that information to the

Federal government.

While source water protection implementation will be primarily a local effort, the measures

and other information in this guidance should assist EPA and states in collaborating with the

many partners needed for source water protection. For example, states could use the maps of

source water areas or the list of priority sources of contamination to partner with other state

agencies, such as Agriculture or Transportation. The Federal government could use such

information to partner with programs such as those managing Federal lands or Federal facilities. 

Collaboration could also occur for programs that can take direct protection actions under

Federal statutes (e.g., Superfund) or through state statutes such as those relative to hazardous

waste facilities.

In addition, states and the Federal government can target assistance for source water

protection. For example, by understanding which communities have advanced implementation

of a source water protection strategy, it would be possible to direct state assistance either to

those communities doing more or to those doing less, depending upon a state’s strategic

approach. The information could also help EPA to target efforts to assist states with

implementation of SWP.
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6. Rationale for How the Measures and Other Information are Indicators to Help

Answer the Key National Questions

Source Water Assessments and Source Water Areas

Question 1: Are the state source water assessments being completed under Section 1453 of

the SDWA?

Question 1 Information:

1.1 Mapped SWAs for CWSs by state. (Other information)

1.2 PWSs with complete assessments, and associated population served - cumulative. 

(Other information)

The requirements for a source water assessment for a PWS, under Section 1453 of the

SDWA, were described in the 1997 Final Guidance to include these actions:

"delineate the boundaries of the areas providing source waters for PWSs, identify, to the

extent practical, the origins of regulated and certain unregulated contaminants in the

delineated area, determine the susceptibility of the PWS to such contaminants...make the

results of the source water assessments available to the public."

That guidance also set forth several components of an approvable state program such as

maps of delineated source water areas.

Each state must provide EPA with information regarding whether it is completing the

assessments under its EPA approved program based on Sections 1452(k)(1)(c) and 1453 of the

SDWA.

In addition, states and EPA can use the maps of source water areas as part of the source

water assessments to demonstrate to other state and Federal programs where, geographically,

they could prioritize protection actions. The mapped source water areas will permit other

programs to overlay the locations of facilities addressed by their program (e.g., underground

injection wells or Clean Water Act permitted sites) or locations of critical areas (e.g., wetlands)

with these source water areas. Also, by placing source water areas in the same database as

watershed areas, it will be easier to see how source water areas compare geographically to

watersheds that are impaired or threatened, as defined under the Clean Water Act.

Thus, the visual overlay displays showing the proximity of source water areas and significant

potential sources of contamination regulated by a program (e.g., underground storage tanks or

landfills) may increase the likelihood that the program will take source water quality into

consideration when making decisions.

States and EPA can therefore develop state-based and national GIS coverages and share

these coverages with other programs, within the bounds of security considerations. EPA is

requesting that the states provide their source water areas to EPA using a EPA/state jointly

developed specific approach. (See the issues and answers regarding these procedures in
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Appendix I under national Question 1.) EPA is continuing a process to develop clear guidelines

for sharing source water area maps at the Federal level across programs.

Threats to Source Waters

Question 2: What threats to sources of drinking water are being found in assessment results?

Question 2 Measures:

2.1 For CWSs, most prevalent categories of significant potential sources of

contamination (aggregated at the state level and nationally, using the assessment

information, split by ground water and surface water systems). (PAM SDW-11)

2.2 For CWSs, most threatening categories of significant potential sources of

contamination (aggregated at the state level and nationally, using the assessment

information, split by ground water and surface water systems). (PAM SDW-11)

States and the Federal government can use these measures to target limited resources to

focus source water program efforts on collaborating with programs that address potential

sources of contamination that are most prevalent or most threatening to source waters. While

some states do not have information on both measures, or have not yet analyzed their

information in this way, these indicator measures should help guide such analyses. In addition,

to the extent that states will be updating assessments, these measures form a recommendation

for what minimum set of state-aggregated information may be useful to states and the Federal

government.

With a prioritized list of sources of contamination, collaboration with other programs should

be more effective in reducing risks to source waters. For example, states in the New England

Region have identified underground storage tanks (USTs) as one of the most prevalent potential

sources of contamination in ground water-based source water areas. Those states, the regional

office and EPA Headquarters are now focusing efforts, such as inspections, to address USTs in

ground water-based source water areas. In some cases, state and Federal governments can

directly implement best management practices, such as in situations where the facilities are

government-owned, or where land is government-owned, such as certain forested lands.

Source Water Protection

Question 3: How are current and future drinking water supplies being protected?

Question 3 Measures and Other Information:

3.1 Percent of CWSs that have source water protection strategies in place and are being

implemented, and associated population served - cumulative. (PAM SDW-9)
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3.2 For CWSs, percentage of source water areas that have source water protection

strategies substantially implemented, and associated population served - cumulative. 

(Strategic Target F) 

3.3 State source water protection activities. (Other information)

(Discussion for Questions 3 and 4 combined is presented below.)

Question 4: Are source water protection actions making a difference to public health

protection?

Question 4 Measure:

4.1 Over time, percent change in CWSs or SWAs for CWSs, and associated population

served, with substantial implementation of source water protection strategies (proxy

for minimized risk to public health). (Strategic Target F)

Since Congress intended for the required assessments to lead to voluntary protection

actions, which can reduce risks to source waters and thereby to public health, this guidance

includes three measures of source water protection implementation: one at the state level and

two at the local level. Unless assessments lead to voluntary protection actions, the purpose of

the SWAP program described in Section 1453 of the SDWA will not be realized.

States and localities across many programs and agencies have implemented many source

water protection actions to protect the source water for CWSs, at least since the early 1970s

when the SDWA and CWA were enacted. The measures and other information in this guidance

should permit states to document current and future actions at the state level, and thus can be

summarized at state and national levels.

The two measures of local source water protection noted under Question 3 above measure

two different statuses in each community for implementation of source water protection

strategies: first, initial implementation, meaning some protection actions are occurring under a

strategy; and second, substantial implementation actions occurring under that same or a

modified strategy.

The key difference between each status for source waters of CWSs will be defined by each

state. States should take the lead in defining when actions for implementing source water

protection strategies will be deemed as meeting the substantial implementation level – and

reported as such. This guidance provides a very broad definition of substantial implementation

to guide development of more detailed state definitions. Although protection programs are

voluntary, these two source water protection measures are based on state leadership in

defining these statuses differently. Also, the measures establish the expectation that states will

institute a process to acquire information sufficient to make judgements about the status of

strategy implementation. This also implies the establishment of a state data system to maintain

this information by CWS along with the ability to report to EPA.

A state's approach to the collection, storage and reporting of this information could be as

basic as asking a local entity to "check-off" that a CWS is at the initial level or substantial level

of implementation, using a state's definitions. This information could be collected by personnel

doing sanitary surveys, possibly even using a “Personal Digital Assistant” to capture this

information for each CWS and transfer it to a state database electronically.
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To aggregate this information at the state level and provide it to EPA, states should structure

information flow from a local entity to the state. That local entity likely would be a governmental

unit or a water supplier. One possibility is for a state to rely on large CWSs to supply the

information separately, the State Rural Water Association to provide information on the CWSs it

works with, and county planners and health or environmental officials to supply information for

the remaining CWSs. There are many other creative ways states can structure a relationship

with their localities to gain information regarding the status of implementation of source water

protection strategies for CWSs. EPA is working closely with ASDWA and GWPC to describe

different state approaches or perhaps to develop new approaches.

Regarding the state narratives for state-level source water protection actions, states and the

Federal government could possibly use this information to both understand the status of

collaborative relationships with other state-level programs and non-government organizations,

and increase the sharing of ideas across states on state-level strategic approaches.

For example, these narratives could explain the cooperative role of State Rural Water

Associations in local source water protection strategy development and implementation. In

many states, Rural Water Association staff are working full-time on source water protection

implementation actions. A narrative that explains the state’s connections to these efforts would

help other states and the Federal government improve these relationships.

Alternatively, a state could emulate another state or group of states that are implementing

specific approaches to program integration with the Clean Water Act. This information should

also equip EPA with better information to explain to stakeholders the full range of source water

protection actions at the state level and possibly inspire such stakeholders to assist states

where there are untapped coordination opportunities.

Another use of the information on the status of state and local source water protection

implementation is to set priorities at the state and Federal levels. As noted before, indicator

measures could assist states in working with local communities, or assist EPA in working with

the states to target staff and financial assistance toward those priorities. Targeting could either

occur to assist communities with CWSs that have already reached the substantial level of

implementation to maintain that status or to assist those communities not yet at that level,

thereby increasing the pace of actions to attain that level of implementation.

This source water protection information is also important for state and Federal

communications to senior program managers and stakeholders relative to reporting progress

toward meeting the congressional goal for SWAPs. Thus, if states report that more

communities have attained the substantial level of implementation of source water protection

strategies, it can be reported, under these measures, that progress is being made toward

minimizing risks to source waters and public health.
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EPA realizes that measuring the status of local source water protection actions is a very

rough proxy for measuring water quality changes. Increasing source water protection actions

even to the substantial level as defined by a state will not guarantee either water quality

improvements or necessarily forestall water quality degradation. Therefore, these measures do

not substitute for current Federal and state programs that monitor for water quality, but are in

addition to those programs. Source water protection programs are just beginning to grow based

on completed source water assessments, and monitoring for regulated drinking water

contaminants in source water areas is generally limited. Use of direct measures of water quality

by states and the Federal government will be considered in future discussions of strategic plan

measures of the results of source water protection implementation.
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Part B. Summary of National and State Source Water Measures and

Information

The following pages present each of the source water protection measures and other

information for the four national questions. This Part includes a description of how the

information should be reported in the spreadsheet format; relevant definitions associated with

the information to be reported; the requested information elements, or specific pieces of

information; and the information quality expected.
14

Question 1: Are the State Source Water Assessments Being Completed Under Section 1453 of the SDWA?

How the Information Should Be Reported Definitions

1.1 Mapped SWAs for

CWSs by state. (Other

information)

States should report polygon information to

EPA using the approach developed in

cooperation with states in 2003. EPA works

with each state on an agreed upon

information management process for the

transfer of SWA polygons.

SWA polygons are the mapped delineated portion of

a ground water area or watershed around each

drinking water source (one or more sources per

SWA) that may contribute pollution to the water

supply. The states should at least report the outer

boundary of each SWA.

For ground water-based CWSs, the map would

include land areas where, if pollutants are spilled or

discharged on the surface, they could filter through

the soil to the ground water and be drawn into a

particular well. The ground water SWA is delineated

in accordance with approved state programs under

the Final National Source Water Assessment and

Protection Programs Guidance, August 1997.

For surface water-based CWSs, the map presents

the entire watershed area upstream of the CWS’s

intake structure to the boundary of the state borders,

i.e., the topographic boundary up to the state’s

border. It is the perimeter of the catchment basin

that provides water to the intake structure.

Attribute information includes the method the state

used to delineate each SWA and other information to

indicate the SWA characteristics and to align the

polygon information with the other CWS and drinking

water source inventory data already reported by the

state to EPA’s SDWIS/Fed database of drinking

water information for the PWSS Program.
15

Information Elements Information Quality

SWA polygons in digital format are digital shape files that

electronically define the area that encompasses a ground

water or surface water SWA. To be usable, the shape files

should align to the unique PWS ID and drinking water source

ID already available through SDWIS/Fed for each CWS water

source.

Key attribute information includes the SWA ID and name

(linked to the CWS and facility IDs), the SWA type (e.g.,

ground water, surface water, or both), the delineation method

code and the characteristics of the specific SWA (e.g.,

assessment zone, protection area, etc.). Additional attribute

information that would be useful, but that is not essential to

describing the SWA polygon, is defined in EPA’s Polygon

Data Model developed with the states in 2003.

Metadata associated with the SWA polygons includes the

delineation method used (e.g., calculated fixed radius) and

the projection (e.g., Albers), used in mapping the polygon.

EPA will perform a quality assurance (QA) review of the information

states provide to ensure that all requested information is present. 

EPA will convert the polygons to a standard projection, using the

Reach Indexing Tool, for national consistency and convert attribute

information to a standard table structure. EPA will only use SWA

polygon information that is aligned to a SDWIS/Fed PWS and facility

IDs.

EPA is working closely with the states throughout the QA process to

ensure the integrity of the polygon information, including the GIS

formatting. See the questions on the polygon collection effort in

Appendix I.
16

Question 1: Are the state Source Water Assessments Being Completed Under Section 1453 of the SDWA?

How the Information Should Be Reported Definitions

1.2 PWSs with complete

assessments, and

associated population

served - cumulative. 

(Other information)

The information includes the percent of

PWSs, and the associated population

served, with assessments completed for all

SWAs.

The percentages will be computed based on

the number of PWSs or SWAs for PWSs in

SDWIS/Fed using the frozen database at

the end of calendar 2000, the year in which

EPA finished approving state Source Water

Assessment Programs.

This information should be reported until

assessments are complete. Only states that

reported less than 100 percent of their

assessments complete in the previous

reporting year will be expected to report

assessments complete.

As defined in each state’s EPA-approved SWAP, an

assessment for a PWS can only be counted and

considered as complete if the four steps of the

assessment have been completed. The four steps

include: (1) delineation of a SWA, (2) identification of

significant potential sources of contamination, (3)

determination of the PWSs susceptibility and (4)

release of the results to the public.
17

Information Elements Information Quality

The percentage of assessments complete by type of water

system–CWS, non-transient non-community water system

(NCWS) and transient NCWS. The percentages will be

computed based on the number of systems in SDWIS/Fed

using the frozen database from the end of 2000.

The population served by those systems with complete

assessments, for each water system type.

States should provide percentages of PWS or SWAs with

completed assessments and the associated population served, from

the state source water assessment database.
18

Question 2: What Threats to Sources of Drinking Water Are Being Found in Assessment Results?

How the Information Should Be Reported Definitions

2.1 For CWSs, most

prevalent categories of

significant potential

sources of contamination

(aggregated at the state

level and nationally, using

the assessment

information, split by

ground water and surface

water systems). (PAM

SDW-11)

Note: reporting will likely be

for either this measure or

Measure 2.2; however,

reporting for both is

acceptable.

States should report the rank order of the

top 5 most prevalent categories of

significant potential sources of

contamination at CWSs or SWAs for CWSs

in their state.

States should provide a ranking from 1

through 5 of the most prevalent categories

of significant potential sources of

contamination, separately for surface waterand ground water-based water supplies.

The rankings for each water source type

should reflect actual state-generated

information from the assessment results. 

For example, the potential contamination

source identified at the highest percentage

of CWS SWAs would be ranked number 1.

Appendix III lists and defines the categories

of significant potential sources of

contamination.

Note: this state information may or may not

change after the first reporting year.

A significant potential source of contamination is

defined in a state’s EPA-approved Source Water

Assessment Program (based on options for the

definition in EPA’s Final National Source Water

Assessment and Protection Programs Guidance of

August 6, 1997 on pages 2-15, 2-16 and 2-17).

Most prevalent potential sources of

contamination

For a CWS, or SWA for CWS:

The most prevalent categories of potential sources of

contamination are those found most often.

For a State:

The top-ranked categories of significant potential

sources of contamination, aggregated for all CWSs

or CWS SWAs, in the state. For example, if largecapacity septic systems are identified most frequently

as a significant potential source of contamination,

then these would be the top ranked category in the

state.

2.2 For CWSs, most

threatening categories of

significant potential

sources of contamination,

(aggregated at the state

level and nationally, using

the assessment

information, split by

ground water and surface

water systems). (PAM

SDW-11) 

Note: reporting will likely be

for either this measure or

Measure 2.1; however,

reporting for both is

acceptable.

States should report the rank order of the

top 5 most threatening categories of

significant potential sources of

contamination at CWSs or SWAs for CWSs

in their state.

States should provide a ranking from 1

through 5 of the most threatening significant

potential sources of contamination,

separately for surface water- and ground

water-based water supplies.

The rankings for each water source type

should reflect actual information from the

assessment results. For example, the

potential contamination source that

threatens the highest percentage of CWS

SWAs would be ranked number 1.

Appendix III lists and defines the categories

of significant potential sources of

contamination.

Note: this state information may or may not

change after the first reporting year.

A significant potential source of contamination is

defined above.

Most threatening categories of significant

potential sources of contamination

For a CWS or SWA for CWS:

The most threatening significant potential sources of

contamination as defined by a state refers to the

categories of existing and potential sources of

contamination that pose the most risk to the CWS or

SWAs for a CWS found in an assessment. Some

states defined “most threatening” in their approach to

susceptibility in their EPA-approved SWAPs.

For a State:

The top-ranked categories of significant potential

sources of contamination, aggregated for all CWSs

or CWS SWAs, in the state. For example, if largecapacity septic systems are identified most frequently

as a threatening significant potential source of

contamination, then these would be the top ranked

category in the state.
19

Information Elements Information Quality

State rankings of the most prevalent categories of potential

sources of contamination, 1-5, with separate rankings for

ground water and surface water CWSs or SWAs for CWSs.

States should provide the information based on information derived

from the state source water assessment database.

State rankings of the most threatening categories of

significant potential sources of contamination, 1-5, with

separate rankings for ground water and surface water CWSs

or SWAs for CWSs.

States should provide the information based on information derived

from the state source water assessment database.
20

Question 3: How Are Current and Future Drinking Water Supplies Being Protected?

How the Information Should Be Reported Definitions

3.1 Percent of CWSs that

have source water

protection strategies in

place and are being

implemented, and

associated population

served - cumulative. 

(PAM SDW-9)

The information for this measure should be

the percent of CWSs or SWAs for CWSs,

and the associated population served, with

SWP strategies in place and being

implemented, by water source type. 

Source water protection strategies should be

developed to guide protection actions. A source

water protection strategy for a CWS/SWA

addresses (as described in 3.2) the identified

significant potential sources of contamination and

other key actions based on the findings of a source

water assessment or management plan and could

provide the foundation for future protection

strategies, to the extent necessary, for CWSs/SWAs

of low relative risk or minimally threatened due to the

natural characteristics of the source water. It can be

based on an adopted written strategy, adopted

written laws, or actions taken by various entities

independent of one, written, strategy, and could

include a process for updating assessment results. It

can also be established through a source water

management system or plan that is designed to

reduce risks identified in a source water assessment,

and that may include specific actions or indicators. A

strategy for a CWS should either: (1) include an

emergency response plan in compliance with the

Public Health Security and Bioterrorism

Preparedness and Response Act of 2002

(Bioterrorism Act); or (2) describe how it will comply

with any relevant actions described in a state's

emergency drinking water plan approved by EPA

pursuant to federal regulations at 40 CFR 142.10(e),

which may include a specific CWS-based emergency

plan.

 A source water area is defined under Section 1453

of the Act and in each EPA-approved state SWAP

program (this could be the same as a state-defined

wellhead protection area for ground water-based

CWSs in some states and could be a conjunctive

delineation). Single source water areas can also be

grouped into another area defined by the state or

substate entity (e.g., wells in a single aquifer, intakes

within the same watershed, etc.).
21

Information Elements Information Quality

Percentage of CWSs or SWAs for CWSs, and the associated

population served, with a strategy in place and being

implemented.

The universe for calculating the percentage is the number of

CWSs and population served in the SDWIS/Fed frozen

database at the end of the year for which the information is

being reported.

States should provide the information based on information in their

source water-related databases.
22

Question 3: How Are Current and Future Drinking Water Supplies Being Protected? 

How the Information Should Be Reported Definitions

3.2 For CWSs,

percentage of source

water areas that have

source water protection

strategies substantially

implemented, and

associated population

served - cumulative. 

(Strategic Target F)

The information for this measure should be

the number or percent of CWSs or SWAs for

CWSs, and related population, with

substantially implemented SWP strategies,

by water source type. Where numbers are

reported, EPA will calculate percentages

based on SDWIS data.

Substantial implementation is occurring when the state

determines: for each CWS (and related population),

strategic protection actions have been or are being taken

to appropriately address state-identified significant

sources of contamination, and possibly other concerns in

a source water assessment, taking into consideration the

sensitivity of the source water to contamination.

Explanatory Definitions for Concepts in the Definition of

Substantial Implementation:

1. “State determines.” The state decides, working with

CWSs and their communities, when a CWS, separately or as

a network or group, has achieved substantial implementation

of a SWP strategy.

2. “Strategic protection actions have been or are being

taken to appropriately address.” Strategic protection

actions for CWSs are based on relevant SWP strategies. 

Actions may reflect implementation of a WHP plan, a local

watershed plan that includes SWP, or a source water

management control system or plan designed to reduce risks

as detailed in a source water assessment, possibly with

specific action indicators in the control system or plan. States

may choose to determine a tailored set of minimum

prevention actions, detailed in a publicly released document

developed through a public involvement process consistent

with state law. Specific actions could include, but are not

limited to:

C zoning and related land-use measures that prohibit or

restrict uses (e.g., by overlay zoning or related actions);

C state or local health regulations (e.g., sanitary setbacks);

C land acquisition/conservation easements;

C enforceable (i.e., enforceable under state and/or local

laws), or voluntary BMPs;

C public outreach, involvement and education programs

related to each significant threat; and/or

C other actions taken under Federal or state statues such

as under the Clean Water Act (e.g., TMDLs, NPS

management).

These appropriate actions may occur for one CWS or multiple

CWSs and be: (a) state-wide, including Federal actions taken

within a state; (b) regionally across jurisdictions; or (c) locally.

3. “Identified significant sources of contamination” can

be the same as the “significant potential sources of

contamination” defined in a state’s EPA-approved SWAP

(see EPA’s national SWAP guidance of August 6, 1997 on

pages 2-15, 2-16 and 2-17). Or the state can identify, for

SWP, a more narrow subset of the significant sources of

contamination.

4. “Sensitivity of the source water to contamination.”

Whether the hydrology or hydrogeology provides a natural

barrier (e.g., a confined aquifer) that minimizes the risk to

public health directly, rather than, or in addition to, source

water strategic protection actions.
23

Information Elements Information Quality

Percentages of CWSs or SWAs for CWSs, and the

associated population served, with a strategy that has been

substantially implemented.

The universe for calculating the percentage is the number of

CWSs and population served in the SDWIS/Fed frozen

database at the end of the year for which the information is

being reported.

States should provide information based on information from their

source water-related databases.
24

Question 3: How Are Current and Future Drinking Water Supplies Being Protected?

How the Information Should Be Reported Definitions

3.3 State source water

protection activities. 

(Other information)

States should provide a narrative report on

state-level source water protection actions

including, but not limited to: collaboration

among state programs and with Federal

programs; state and local partnerships with

governments or private entities for

protection; direct protection actions; and any

other relevant actions during the year for

which information is being reported.

This narrative information will permit states to

document the current actions each year. Actions that

will likely be described would encompass both

actions at the state level to coordinate and leverage

across state government and with Federal agencies,

but also actions to increase local protection efforts. A

full accounting of these actions will provide a good

context for the percentages of CWSs or SWAs for

CWSs with implemented or substantially

implemented SWP strategies.
25

Information Elements Information Quality

A narrative description of how the state defines the concepts

in measures 3.1 and 3.2, particularly what is meant by a

“strategy developed and initially implemented,” and a

“substantially implemented strategy.” The narrative should

also describe the state’s source water protection activities for

the year.

States should report using all available information and, likely, a

variety of information sources.
26

Question 4: Are Source Water Protection Actions Making a Difference to Public Health Protection?

How the Information Should Be Reported Definitions

4.1 Over time, percent

change in CWSs or SWAs

for CWSs, and associated

population served, with

substantial

implementation of source

water protection

strategies (proxy for

minimized risk to public

health). (Strategic

Target F)

Based on the state-level percentage

provided in Measure 3.2, this measure

reflects the year-to-year change in the

percentages of CWSs or SWAs for CWSs

with substantially implemented source water

protection strategies.

Aggregated by state and then nationally, changes in

the percentages CWSs or SWAs for CWSs with

substantially implemented SWP strategies. The

trend is the change in percentage.
27

Information Elements Information Quality

This measure includes no new information elements. 

Information from Measure 3.2, percentage of SWAs for

CWSs with substantially implemented SWP strategies, will be

used to compute the measure.

See information quality under Questions 3.1 and 3.2.

29

Part C. Integrated Structure and Framework for Source Water

Measures and Information Reporting

Two options available to states for reporting source water information are: (1) completing

spreadsheets and submitting them to EPA and (2) electronic reporting and data transfer using

water system level data.

1. Spreadsheets and Narratives

EPA will distribute the spreadsheets, which are essentially electronic versions of Appendix

III. States are encouraged to provide the information in the spreadsheets, using this Guidance

and the instructions provided with the spreadsheets. In addition, states are encouraged each

year to provide, for Measure 3.3, a narrative description of their source water protection

strategies and actions.

2. Optional Electronic Reporting on Pilot Basis using Water System Level Data

At their discretion, states may use an electronic reporting approach, developed by EPA and

GWPC based on a Source Water Protection (SWP) data module in 2003. This information

may be at the system-level or the source water area-level and may vary by measure. Electronic

reporting enables EPA to accept both the delineated SWA polygons in Geographic Information

System (GIS) format and the CWS-level or SWA-level tabular data needed to develop the

spreadsheets for the source water measures and other information. Of course, states could

provide other information, such as for non-community water systems, if desired. Thus, if a state

uses this Source Water Protection data module, EPA fully expects to generate the spreadsheets

from the more detailed data submitted.

GWPC and OGWDW have generated a report on the 2003 Source Water Protection data

module pilot effort, which is available to the states and regions upon request. A copy is

available from Carl Reeverts (Reeverts.Carl@epa.gov).

Following publication of this Guidance, EPA and GWPC fully expect to produce a document

explaining the details of how to use the Source Water Protection data module for reporting. 

EPA intends to continue to work with GWPC through the FY 2008 reporting cycle to improve the

system, making adjustments based on the suggestions in the pilot report and from subsequent

discussions between EPA and state users.

The SWP data module is illustrated in the “SWP Database Model” diagram below. The data

module will also include a table of the data elements and attributes EPA is collecting (not shown

here). These tables will be included in detail in the subsequent EPA/GWPC document.

Source water assessment and protection data will flow from the states to EPA’s data module

via an XML schema and through EPA’s central data exchange (CDX) into the SWP data

module. GWPC supported development of the pilot XML schema consistent with EPA’s SWP

data module and provided technical assistance and support to the pilot states in populating the

XML schema. OGWDW, in turn, facilitated the transfer of the populated XML schema through

CDX into EPA’s ORACLE-based SWP data module, which is kept in a secure database with a

contractor.

 Since this process is still in the pilot stage, EPA intends to provide whatever support is

necessary to those states that volunteer to pursue this option.
30

2. Source Water Protection Relational Database Management System (RDBMS):

– Conceptual Data Flow from State to SWP Database Thru CDX

State U.S. EPA (Regions and HQ)

State 

SWP 

Data 

Base 

Drinking 

Water 

(SDWIS/Fed) 

Database

State 

Drinking 

Water 

Data 

Reports/Pivot 

Tables/GIS 

Reports thru 

Drinking 

Water Data 

Warehouse

(OGWDW Pilot

State Data: XML Schema:

SWP 

Database

State 

XML 

File

GWPC 

Pilot: 

State 

XML 

File

compatible

GWPC 

Pilot: Data 

reformatted 

to fit into 

XML 

schema 

EPA Drinking 

Water Databases:

Drinking Water Data 

Warehouse:

SWA 

Polygon 

RAD

E

P

A

C

e

n

t

r

a

l 

D

a

t

a

E

x

c

h

a

n

g

e

C

D

X
31

Appendix I–Issues and Answers Raised on the Initial Reporting

Guidance of 2003

There were various issues raised after the release of the Initial Reporting Guidance in

August, 2003. Below are answers to those questions that are directly relevant to the Final

Guidance.

General Issues

Information on community water systems (CWSs) and public water systems (PWSs).

States will have the opportunity to share with EPA information on CWSs and, if a state

prefers, also for PWSs. Because of limited resources for prevention, and since stakeholders

are only beginning to focus such prevention efforts, initial efforts will likely focus mostly on

CWSs. The mapped areas for assessments for non-CWSs are still critical in order to ensure

that key Federal and state agencies know the locations of source water areas and assessment

results for non-CWSs so they can implement prevention efforts in those areas. For example,

the U.S. Department of Agriculture’s Forest Service could implement such prevention actions for

the non-CWSs operated by them or located near forests and provide effective prevention

actions to protect the consumers of those non-CWSs.

Measuring by source water areas (SWAs) or CWSs for measures other than Measure 1.2,

Completed Assessments.

While both source water area and CWS information is expected to address the information

needs for these measures, states are encouraged to share one type of information only: either

for CWSs or for source water areas. EPA intends to work with individual states using SWAs to

convert to CWSs.

Measuring EPA progress in integrating SDWA and CWA actions to protect the Nation’s

drinking waters and public health.

States and EPA are working to fully utilize programs under these two statutes to help protect

drinking water sources. The many actions EPA is undertaking are described in Section 4 of

Part A. The National Water Program Guidance for 2005, which is available on the Office of

Water’s Web site, includes measures for EPA implementation to integrate these statutes.

Substance of state-wide and national reports on program measures and other

information.

While state and national reports on the measures and other information will vary in content

and structure, the reports should help state and national programs prioritize actions to better

achieve program goals and objectives. These reports could help EPA and other Federal

programs adjust the level of staff; financial resources; and technical assistance, training and

technology transfer functions to help states and localities implement source water protection

programs. For example, if agriculture is identified as being among the most prevalent significant

sources of contamination in one region of the country, resources for programs addressing

agriculture could be focused in that region. Or, if septic systems were identified as a prevalent

potential source of contamination for ground water-based CWSs, national program resources

could be directed to better address septic systems. Completing the first national reports should

set in place a process for jointly working with states and their national organizations to produce
32

future reports. Likewise, if states decide to do reports, this could form a process for jointly

working across state agencies and with local communities to gather information relevant for

source water protection.

Reporting using “population” as a metric for source water assessments completed and

for source water protection implementation.

The Guidance includes reporting both for water systems and for population served by those

systems. This should permit state and national reports to use summary information that

includes both; that is, the populations associated with a particular number or percentage of

water systems. Just as the national reports would be based on the water system information in

SDWIS, so would the population information.

Reporting on future sources of drinking water, either ground water or surface water.

There is no expected reporting under this Guidance for waters that a state has not assessed

either under its SWAP Program or under any updated assessments. However, while the Source

Water Assessment Program required by the 1996 Amendments to the SDWA focused on

current sources of drinking water as delineated under EPA-approved SWAP programs, EPA’s

1997 SWAP Guidance recommended updates to assessments including assessments for new

drinking water systems. The SWAP Program is not intended to deter states from prudent

planning for future water supplies that may focus protection efforts in a comprehensive

protection approach on surface and ground waters that are not now used for drinking water, but

may be in the future.

Question 1: Are the State Source Water Assessments Being Completed under 

Section 1453 of the SDWA?

Source water areas for assessment and/or protection.

For the polygon information collection for all states, EPA expects to accept those areas the

state will share so long as it is clear what is being shared and how it was developed. At a

minimum, EPA requests the SWA boundaries used by a state in developing its source water

assessments (i.e., the area in which the state conducted its most detailed contaminant source

inventory and susceptibility determination). This could include multiple delineation zones

nested into one outer source water area boundary. Since the delineation methods for CWSs of

similar size vary dramatically by state, EPA intends to work with each state based on the state’s

information. States that have separate SWA boundaries for assessments, as compared to

boundaries for protection, can submit both. EPA has not identified information needs for

separate source water area boundaries, but expects to make provisions for identifying such

separate boundaries in the Agency’s SWA information repository, which is with a contractor and

will be secure.

Availability of mapped SWAs to EPA programs, Federal agencies and state programs.

One of the key benefits of making mapped SWAs for CWSs available to Federal and state

agencies is that knowing the location of such areas could help these agencies focus future

assessment and prevention actions within SWAs. EPA’s objective is to build a

nationally-consistent geospatial data coverage to represent, for the PWSS Program, the intake

and well inventory point locations and SWAs. EPA recognizes its responsibility to manage

sensitive locational information in a secure manner. Therefore, EPA expects to implement a
33

policy which will both achieve the benefits of making the SWAs available to EPA programs and

Federal agencies, and ensure that the information will be used in a responsible manner.

What is the status of the SWA polygon information collection?

OGWDW initiated the development of national GIS coverage of the state-delineated source

water areas in October 2002. As of December, 2004 EPA has GIS coverages of some or all the

SWAs from 24 states. A second round of SWA information collection will continue to be

voluntary for the states. All SWA polygon information collection from the states will be

coordinated through the EPA regions.

How will the polygon information received from the states be processed and where will it

be stored?

OGWDW expects to store the SWA polygon shape files and associated attribute information

from the states in a secure server developed and maintained by Research Triangle Institute

(RTI), a contractor to EPA. OGWDW expects to hold the validated SWA polygon information in

the secure server at RTI until OGWDW and each state agrees that it is appropriate to transfer it

to a server at EPA for EPA use.

The process of soliciting and validating the SWA information received from each state

involves a number of steps:

C OGWDW expects to first pre-screen the raw state information to align it to locational

information already submitted by the states to SDWIS/Fed. Since each state’s file format

and attribute information are unique, OGWDW intends to work as necessary with the

individual state to resolve information and format consistency issues.

C After aligning the state information to SDWIS/Fed, RTI should use software to convert each

shape file to a standard geographic projection that identifies a unique area. This should be

used to populate the database, along with applicable Federal Geographic Data Committee

(FGDC) data and other attribute data. The polygons and their attributes should not be

altered from what the state provides to EPA. Data gaps should be addressed on a

case-by-case basis with the states.

C Finally, EPA expects to provide its geospatial projection and associated attribute table to the

state for review. OGWDW is requesting that each state affirm that EPA’s representation of

the state data is consistent with what the state is using.

What if the polygons are not tagged specifically to SDWIS/Fed public water supply

identification numbers?

EPA intends to only use SWA polygon information that is aligned to SDWIS/Fed PWS and

facility IDs. Other than aligning the information to the existing inventory records in SDWIS/Fed,

all other information that EPA will use should be converted (through collaboration with the

regions and states) to a standard table structure.

What if national and state maps do not agree?

OGWDW intends to maintain SWA information from a state, and EPA will not change the

shape of any state polygons. It is possible that OGWDW will maintain converted SWA polygon

information that has been affirmed by the state as representative of the data maintained by the
34

state. OGWDW will likely also maintain a record of when the information was received from the

state to assure continuing information comparability. Updates to OGWDW’s SWA database will

likely be based only on information updates received from the states.

Why is the measure of Tribal assessments completed not included in this Guidance?

While source water assessments for public water supplies on tribal lands were not required,

EPA’s 1997 Final National Source Water Assessment and Protection Programs Guidance

recommended that “each tribe implement such a program to the extent appropriate resources

are available to do so.”

Federal Direct Implementation programs have been working with tribes to do assessments

and, in some cases, have done much of the actual assessment work in cooperation with tribal

staff. Because this Final Guidance is written for states, and there is a separate overall EPA

Tribal Strategic Plan with measures, information on the tribal measure is not included here. The

measure for tribal assessments is PAM SDW-10 in the National Water Program Guidance for

2006, “number of Tribal community water systems that have completed a source water

assessment consistent with national guidelines.”

Question 2: What Threats to Sources of Drinking Water Are

 Being Found in Assessment Results?

Measuring most prevalent and most threatening significant potential sources of

contamination.

Some states may find it difficult to summarize results on the significant potential sources of

contamination identified in their source water assessments. However, this information is useful

in helping to focus the appropriate state and Federal resources for prevention actions.

Based on a state’s approved SWAP, there is a possibility that states will only have one data

set and not the other, e.g., most prevalent or most threatening, but not both. However, both are

included in the measures so all states can report using their current data system.

For these measures, states are strongly encouraged to share information by ranking the top

five categories of significant potential sources of contamination in source water areas for CWSs

or for CWSs. Providing this information will increase its utility to states and the Federal

government to focus protection actions relative to priority sources of contamination.

Eliminate from PAM 11 in the upcoming 2006 National Water Program Guidance the most

threatening categories of sources of contamination.

As noted above, while some states may only be able to report the most prevalent sources of

contamination, other states may only have aggregated information on the most threatening

sources. At the state and national levels, understanding the differences in the categories will

be important. The most prevalent category can be a proxy for the most threatening category,

but not a substitute. If a state defined the most threatening sources in its SWAP Program, that

information should be critical at the state level. At the national level, it is useful to know how

many states will report similar categories of information. With a substantial number of states

reporting this information, possibly even a third, it should provide the national program an

understanding of whether the top five categories of most prevalent sources of contamination are

different than or similar to the most threatening categories.
35

 Question 3: How Are Current and Future 

Drinking Water Supplies Being Protected?

Counting when a source water protection strategy is in place and initial implementation

is occurring for a CWS(s) or SWA(s) of a CWS(s).

While this final Guidance provides flexibility to states in defining this status, the key

ingredient is that the state have a clear definition of a SWP strategy in place. Source water

protection strategies should be developed to guide protection actions. A source water

protection strategy for a CWS/SWA addresses identified significant potential sources of

contamination and other key actions based on the findings of a source water assessment or

management plan, and could provide for future protection strategies, to the extent necessary,

for CWSs/SWAs of low relative risk or minimally threatened due to the natural characteristics of

the source water. It can be based on an adopted written strategy, adopted written laws, or

actions taken by various entities independent of one, written, strategy, and could include a

process for updating assessment results. It can also be established through a source water

management control system or plan designed to reduce risks as detailed in a source water

assessment, possibly with specific action indicators in the control system or plan. A strategy for

a CWS should either: (1) include an emergency response plan in compliance with the Public

Health Security and Bioterrorism Preparedness and Response Act of 2002 (Bioterrorism Act); or

(2) describe how it will comply with any relevant actions described in a state's emergency

drinking water plan approved by EPA pursuant to federal regulations at 40 CFR 142.10(e),

which may include a specific CWS-based emergency plan.

Source water protection actions can be implemented either before, during, or after a

strategy has been developed; however, ongoing implementation should occur for it to be

countable. For example, most CWSs are implementing source water protection actions in

delineated source water areas for specific sources of contamination, such as point sources

(shallow underground injection wells) or nonpoint sources (stormwater runoff). Such program

actions may have been in place prior to source water protection strategy development, but are

ongoing. Therefore, for CWSs or SWAs for CWSs, we fully expect to count them as achieving

initial implementation if such actions are ongoing, and a strategy is in place.

Necessity of including a contingency plan or CWS-specific emergency plan in a source

water protection strategy for a CWS.

As noted in the previous answer, for CWSs covered by the Public Health Security and

Bioterrorism Preparedness and Response Act of 2002, this Guidance states that a strategy is

not counted unless it is in compliance with that Act. For all other CWSs, the Guidance states

that a “State, substate, or CWS-specific emergency plan should be in place.” Contingency

planning has been a part of the SDWA Section 1428 since 1986 for ground water-based PWSs

covered by EPA-approved state wellhead protection programs. Nothing in the 1996

Amendments to the SDWA or in the 2002 Bioterrorism Act changed that language in Section

1428.

Measuring substantial implementation of source water protection strategies as a proxy

for minimizing risks to public health in a SWA.

To measure “substantial implementation,” this Guidance recommends that states define

substantial implementation of a source water protection strategy using, as a beginning point, the

definition in Part B (which is also in Appendix IV). States will have great latitude to set policies

for determining which sources of contamination are significant for protection actions and for
36

determining the nature and extent of the actions needed to meet the substantial level of strategy

implementation.

The assumption underlying this measure is that substantial implementation of protection

actions that address significant sources of contamination will reduce loadings of contaminants

to source waters. Thus, as loadings are reduced, the quality of waters should be maintained or

increase, and risks to public health should decrease, or at least be maintained at current levels.

It would be better to measure risk minimization directly, using water quality changes. 

However, there is very limited monitoring data available to do this, and future resources to

implement such a monitoring system are uncertain.

 EPA and the states could use other information to characterize risk changes also, such as

increases or decreases in watershed ratings described in the CWA Section 305(b)/303(d)

biennial reports, or contamination detects and compliance rates reported in state or Federal

drinking water supply databases.

States will likely establish more or less stringent definitions for the content of source

water protection strategies, strategies initially implemented, or strategies substantially

implemented.

Providing states flexibility in these definitions is critical, given the lack of statutory

requirements. This could indeed lead to different definitions. State narrative information,

however, should permit EPA to explain in any report the variation among the states in the

percentages of CWSs at the initial or substantial levels of implementation. It should not be

assumed that states with more stringent definitions will have lower numeric results. Those

states may, in fact, have the same or better results due either to past or current implementation

of preventive actions that meet the more stringent definitions.

Reporting on strategies initially implemented should permit states to count CWSs that

only have a strategy in place, or only have protection actions and no strategy.

State definitions of a strategy initially implemented should include protection actions already

implemented, and in fact, could constitute a strategy as well as implementation. That is, by

doing the initial protection actions for a CWS, the totality of these actions can constitute the

strategy. This may be more appropriate where there are only a few sources of contamination

that are significant and a few source water protection actions would be needed to address them.

For a community that has a written strategy, but has done nothing to implement it, either

before or after the strategy was established, we fully expect not to count it as having a strategy

initially implemented.

Question 4: Are Source Water Protection 

Actions Making a Difference to Public Health Protection?

Measuring how SWP actions will make a difference to public health protection.

As noted above, EPA expects to use substantial implementation of source water protection

strategies as a proxy for minimizing risk to public health. To use these measures nationally

each year, states would need to report the extent to which these strategies are being

implemented, i.e., the percent of CWSs or SWAs for CWSs achieving substantial

implementation of SWP strategies. The percentage change from year-to-year, therefore, would
37

measure whether prevention actions are making a difference. This percentage change would

provide a general description regarding whether or not past prevention actions are making a

difference in minimizing risks to public health.

Reporting and Database Issues

For the 2006, 2007, and 2008 reporting, what are the states’ reporting options?

As described in Part C of this Guidance, states may: (1) use the spreadsheet files provided

by EPA, or (2) report using the source water reporting module process. The source water

reporting module will likely continue to be piloted for the 2006 to 2008 period and any state may

use it. Since information provided via the reporting module is for each CWS, or for each SWA

for a CWS (or for PWSs if a state prefers), more information is provided to EPA than just the

spreadsheet summary data. EPA expects to place the SWP module information in a secure

database with a contractor until a place in EPA’s database has been developed. EPA would

then generate the spreadsheet of summary information, in cooperation with the states, so

comparable information is available for analysis across all states.

For states that want to continue using the pilot source water reporting module, EPA has

developed a source water data framework for efficient and cost-effective sharing of source

water data elements between states and EPA. Working with the Ground Water Protection

Council, EPA has developed and pilot tested a data exchange mechanism to accommodate the

transfer of state data to EPA’s central data exchange (CDX), using an XML schema that

converts state-specific formats to the EPA standard.

Is the reporting required?

For Strategic Measure F of the 2003 to 2008 Strategic Plan (Substantial Implementation of

Source Water Protection Strategies), EPA will likely report on this measure as part of any report

under the Strategic Plan. States are obligated, to the extent that they obligate themselves

through agreements with EPA, to provide information for this measure or for the Program

Activity Measures or other information. EPA strongly recommends that states provide this

information, whether required by agreement or not.

Every state must report on assessments completed. States were required under SDWA

Section 1453 to implement the Source Water Assessment Program and all spent funds for such

a program under Section 1452(k)(1)(c), the Drinking Water State Revolving Fund (DWSRF). 

States therefore have an obligation to share information with the Federal government regarding

the status of completing the assessment program.

Information quality.

Information is expected to be of high quality, but it is understood that as the quality of the

information increases, the burden on the states to provide the information increases as well. 

EPA strongly recommends that states collect and store the information for each CWS in a

state-level database. Various processes can be developed to aggregate information. For

measures and other information on the assessment program, states should be able to

aggregate information collected, although there are a variety of challenges for states in the

endeavor, depending on how the assessment information is stored at the state level. For the

protection measures for sub-state areas, such as for CWSs, states may need to establish a

process for collecting local information. One option could be to use a state-based certification
38

process, or a local self-certification process for CWSs, on the status of local source water

protection implementation actions.

Reporting on CWSs that are in communities substantially implementing protection

actions will be difficult given resource limitations and practical issues in obtaining local

protection information, such as reporting capability.

States are requested in this Guidance to back up summary information reported to EPA with

CWS-by-CWS information. States can report this more detailed information if they choose to do

so. The effort needed to document local specific actions is a significant burden, and many

states will likely not have such a data system. Instead, states are likely to have a definition of

what constitutes implementation at different levels, and report whether a CWS is or is not

meeting that definition.

EPA understands the states’ financial constraints based on previous published reports from

the states and their national organizations. However, for the status of protection actions to be

understood at the state and national levels, EPA recommends that states develop some

systematic approach to collecting the information. That approach does not have to be very

elaborate. A state could, for example, ask CWS managers to report whether the community for

the CWS meets the definitions of implementation levels set by the state.

Using best professional judgement as compared to having a state database to back up

state reported summary information on the levels of source water protection

implementation.

When states report summary information on assessments completed, that information is

based on a database. Similarly, the quality of summary information on the levels of source

water protection implementation will be much better if, in fact, states will have the backup

information specifically on which CWSs are at which status. Without this backup information,

states will not be able to target assistance to CWSs, nor be able to identify, if asked, the basis

for the summary information.
39

Appendix II–Crosswalk of National Questions, Measures, and

Information Elements

Question Source Water Measures and

Other Information

Information Element

1. Are the state

source water

assessments being

completed under

Section 1453 of the

SDWA?

1.1 Mapped SWAs for CWSs by state. 

(Other information)

SWA polygons in digitized format

(ground water and surface water).

Attribute information and other

relevant information

1.2 PWSs with complete assessments,

and associated population served -

cumulative. (Other information)

Percent of PWSs with complete

assessments and the associated

population served.

2. What threats to

sources of drinking

water are being found

in assessment

results?

2.1 For CWSs, most prevalent

categories of significant potential

sources of contamination (aggregated

at the state level and nationally, using

the assessment information, split by

ground water and surface water

systems). (PAM SDW-11)

State rankings of the top 5 most

prevalent categories of potential

sources of contamination for CWSs

or SWAs for CWSs (using national

agreed upon list attached to this

guidance).

2.2 For CWSs, most threatening

categories of significant potential

sources of contamination (aggregated

at the state level and nationally, using

the assessment information, split by

ground water and surface water

systems). (PAM SDW-11) 

State rankings of the top 5 most

threatening categories of potential

sources of contamination for CWSs

or SWAs for CWSs (using national

agreed upon list attached to this

guidance).

3. How are current

and future drinking

water supplies being

protected?

3.1 Percent of CWSs that have source

water protection strategies in place and

are being implemented, and associated

population served - cumulative. (PAM

SDW-9)

Percent of CWSs or SWAs for

CWSs, and the associated

population served, with a strategy

in place and being implemented.

3.2 For CWSs, percentage of source

water areas that have source water

protection strategies substantially

implemented, and associated

population served - cumulative. 

(Strategic Target F) 

Percent of CWSs or SWAs for

CWSs, and the associated

population served, with a strategy

that has been substantially

implemented.

3.3 State source water protection

activities. (Other information)

State narrative.

4. Are source water

protection actions

making a difference to

public health

protection?

4.1 Over time, percent change in CWSs

or SWAs for CWSs, and associated

population served, with substantial

implementation of source water

protection strategies (proxy for

minimized risk to public health).

(Strategic Target F)

No new information elements. 

Percent change in substantial

strategy implementation is a proxy

for minimized risk to public health.

(Information elements under 3.2

above.)

See Part B for definitions of the information elements.
40

Appendix III–Representations of Reporting Spreadsheets

The following pages are generic representations of the spreadsheets that regions and states

should use to report the indicator measures and other information. Additional information to be

contained in or with the spreadsheet files to be distributed includes:

C SDWIS/Fed data on the number of systems and population:

– December 2000 frozen database information for assessments completed (Measure 1.2).

– The most recent year’s fourth quarter frozen database information for the source water

protection measures (Measures 3.1 and 3.2).

C Each state’s prior year data, to be used as a reference, beginning in Year 2 of the

information collection.

C Complete instructions for filling out the spreadsheets that reflect the definitions and other

information in Part B.

C Each spreadsheet will indicate the FY for which the information is to be reported.

Note: This collection of information will be consistent with the Paperwork Reduction Act.
41

Complete Source Water Assessments

Public Water Systems (PWSs) or Source Water Areas for PWSs

---------------------------------------------

States that reported 100% for all three rows in the previous year do not

need to fill in this table

State 

Reporting level (circle one): System / Source water area

Percent of

Systems/SWAs with

Complete Assessments

Population 

Served

Community water systems

Non-transient non-community

water systems 

Transient non-community water

systems
42

Most Prevalent Significant Potential Sources of Contamination

---------------------------------------------------------------

Pick and mark the top five in priority order number 1 through 5 source categories of

CWSs or SWAs for CWSs

State: 

Significant Potential Sources of Contamination

SWAs CWSs

GW-based SW-based GW-based SW-based

1. AGRICULTURE

Concentrated animal feeding operations

Other animal feeding operations

Grazing

Crop production

Fertilizer/pesticide/herbicide applications

Farm chemicals and equipment (storage and sales)

Agricultural drainage

Agricultural irrigation wells

Aquaculture

Silviculture/managed forests

2. WASTEWATER

Municipal sanitary waste treatment and disposal

(commercial, domestic, and industrial waste)

Septic (on-site sewage disposal) systems

Large-capacity septic systems

Sewer collection systems/sewer lines

Combined sewer overflows

Land application of sludge (offsite of waste treatment plants)

Class I injection wells

3. STORMWATER

Stormwater discharges (permitted and others) 

Stormwater retention basins

4. COMMERCIAL/INDUSTRIAL

Automobile related activities

 Gas stations (includes historic gas stations)

 Other automotive activities

Chemical/petroleum processing/storage

Dry cleaners

Manufacturing 

Wood/lumber/paper processing

Industrial discharge and disposal (process water); includes

land treatment

Underground storage tanks (not leaking)

Above ground storage tanks (not leaking)

Chemical and petroleum pipelines

Landscape maintenance

Mining/resource extraction

 Active mining

 Inactive/abandoned mining

 Sand and gravel mining

 Petroleum extraction (includes Class II wells)
Most Prevalent Significant Potential Sources of Contamination

---------------------------------------------------------------

Pick and mark the top five in priority order number 1 through 5 source categories of

CWSs or SWAs for CWSs

State: 

Significant Potential Sources of Contamination

SWAs CWSs

GW-based SW-based GW-based SW-based

43

5. TRANSPORTATION

Airports

Railroads/subways

Freeways/State highways

Roads/streets

Transportation maintenance facilities

Ports/harbors

6. WASTE PROCESSING/MANAGEMENT

Landfills

Hazardous waste disposal sites

Unauthorized dumping

Junkyards

7. CONTAMINATED SITES

Leaking underground storage tanks

Known contamination sites/plumes/spills

8. PHYSICAL LAND & WATER ALTERATION

Erosion and sedimentation (includes construction and

sediment resuspension)

Production wells 

Injection wells/dry wells/sumps/abandoned wells

9. RESIDENTIAL HOUSING

Underground and above ground storage tanks

Septic (on-site sewage disposal) systems 

Lawn and garden care

10. RECREATION

Recreation activities (other than boating)

 Golf courses

Surface water recreation areas

 Body contact recreation areas

 Recreational boating areas

11. OTHER MAJOR FACILITIES

Military installations

Federal facilities

Utilities/powerplants

Hospitals

Laboratories 

Cemeteries and mortuaries

12. MISC. ENVIRONMENTAL THREATS

Natural sources (e.g., arsenic, radon, wildlife)

Atmospheric Deposition
44

Most Threatening Significant Potential Sources of Contamination

---------------------------------------------------------------

Pick and mark the top five in priority order number 1 through 5 source categories of

CWSs or SWAs for CWSs

State: 

Significant Potential Sources of Contamination

SWAs CWSs

GW-based SW-based GW-based SW-based

1. AGRICULTURE

Concentrated animal feeding operations

Other animal feeding operations

Grazing

Crop production

Fertilizer/pesticide/herbicide applications

Farm chemicals and equipment (storage and sales)

Agricultural drainage

Agricultural irrigation wells

Aquaculture

Silviculture/managed forests

2. WASTEWATER

Municipal sanitary waste treatment and disposal

(commercial, domestic, and industrial waste)

Septic (on-site sewage disposal) systems

Large-capacity septic systems

Sewer collection systems/sewer lines 

Combined sewer overflows

Land application of sludge (offsite of waste treatment plants)

Class I injection wells

3. STORMWATER

Stormwater discharges (permitted and others) 

Stormwater retention basins

4. COMMERCIAL/INDUSTRIAL

Automobile related activities

 Gas stations (includes historic gas stations)

 Other automotive activities

Chemical/petroleum processing/storage

Dry cleaners

Manufacturing 

Wood/lumber/paper processing

Industrial discharge and disposal (process water); includes

land treatment 

Underground storage tanks (not leaking)

Above ground storage tanks (not leaking)

Chemical and petroleum pipelines

Landscape maintenance 

Mining/resource extraction

 Active mining 

 Inactive/abandoned mining

 Sand and gravel mining

 Petroleum extraction (includes Class II wells)
Most Threatening Significant Potential Sources of Contamination

---------------------------------------------------------------

Pick and mark the top five in priority order number 1 through 5 source categories of

CWSs or SWAs for CWSs

State: 

Significant Potential Sources of Contamination

SWAs CWSs

GW-based SW-based GW-based SW-based

45

5. TRANSPORTATION

Airports

Railroads/subways

Freeways/State highways

Roads/streets

Transportation maintenance facilities

Ports/harbors

6. WASTE PROCESSING/MANAGEMENT

Landfills

Hazardous waste disposal sites

Unauthorized dumping

Junkyards

7. CONTAMINATED SITES

Leaking underground storage tanks

Known contamination sites/plumes/spills

8. PHYSICAL LAND & WATER ALTERATION

Erosion and sedimentation (includes construction and

sediment resuspension) 

Production wells 

Injection wells/dry wells/sumps/abandoned wells

9. RESIDENTIAL HOUSING

Underground and above ground storage tanks

Septic (on-site sewage disposal) systems 

Lawn and garden care

10. RECREATION

Recreation activities (other than boating)

 Golf courses

Surface water recreation areas

 Body contact recreation areas

 Recreational boating areas

11. OTHER MAJOR FACILITIES

Military installations

Federal facilities

Utilities/powerplants

Hospitals

Laboratories 

Cemeteries and mortuaries

12. MISC. ENVIRONMENTAL THREATS

Natural sources (e.g., arsenic, radon, wildlife)

Atmospheric Deposition
46

Explanatory Notes on Specific Categories for Significant Potential Sources of Contamination for those

that needed examples 

Sources Notes

1. AGRICULTURE

Concentrated animal feeding operations 

Other animal feeding operations Includes confined animal feeding operations.

Grazing Includes riparian and/or upland pasture and range grazing.

Crop production Includes irrigated and non-irrigated crop production and

specialty crop production (e.g., horticulture, citrus, nuts,

fruits).

Fertilizer/pesticide/herbicide applications

Farm chemicals and equipment (storage and

sales)

Agricultural drainage

Agricultural irrigation wells

Aquaculture

Silviculture/managed forests Includes harvesting, restoration, residue management; forest

management (e.g., pumped drainage, fertilization, pesticide

application); logging road construction/ maintenance; and

silvicultural point sources.

2. WASTEWATER

Municipal sanitary waste treatment and

disposal (commercial, domestic, and industrial

waste)

Includes dry and/or wet weather discharges of commercial,

domestic, and industrial waste from major and/or minor

municipal point sources; Includes on site lagoons/liquid

wastes and land disposal of sludge (offsite sludge

application should be noted separately). Also includes

package plants.

Septic (on-site sewage disposal) systems

Large-capacity septic systems

Sewer collection systems/sewer lines Includes collection system failures and leaking sewer lines.

Combined sewer overflows

Land application of sludge (offsite of waste

treatment plants)

Class I injection wells

3. STORMWATER

Stormwater discharges (permitted and others) Includes permitted nonindustrial and industrial discharges

and other urban runoff/storm sewers; also includes illicit

connections, illegal hookups, and dry weather flows.

Stormwater retention basins

4. COMMERCIAL/INDUSTRIAL

Automobile related activities

 Gas stations (includes historic gas stations)

 Other automotive activities

Chemical/petroleum processing/storage

Dry cleaners

Manufacturing Includes electronics manufacturing, plastics/synthetics

producers, metal plating and finishing, homes, and furniture.

Wood/lumber/paper processing

Industrial discharge and disposal (process

water); includes land treatment

Includes major and minor industrial point sources, and land

treatment of process water.

Underground storage tanks (not leaking)

Above ground storage tanks (not leaking)

Chemical and petroleum pipelines

Landscape maintenance Includes landscaping around commercial facilities such as

malls and office parks.
Explanatory Notes on Specific Categories for Significant Potential Sources of Contamination for those

that needed examples 

47

Mining/resource extraction

 Active mining Includes active surface mining, subsurface mining, placer

mining, dredge mining activities, and Class III injection wells;

mill tailings, mine tailings, and acid mine drainage. 

 Inactive/abandoned mining Includes the impacts of past surface, subsurface, placer, and

dredge mining activities and associated mine tailings, mill

tailings, and acid mine drainage.

 Sand and gravel mining

 Petroleum extraction (includes Class II wells)

5. TRANSPORTATION

Airports

Railroads/subways

Freeways/State highways

Roads/streets

Transportation maintenance facilities Includes salt storage and equipment storage and

maintenance.

Ports/harbors

6. WASTE PROCESSING/MANAGEMENT

Landfills

Hazardous waste disposal sites

Unauthorized dumping

Junkyards

7. CONTAMINATED SITES

Leaking underground storage tanks

Known contamination sites/plumes/spills

8. PHYSICAL LAND & WATER ALTERATION

Erosion and sedimentation (includes

construction and sediment resuspension)

Includes highway, road, and bridge construction and land

development and sediment resuspension.

Production wells Includes wells for withdrawing ground water.

Injection wells/dry wells/sumps/abandoned

wells

9. RESIDENTIAL HOUSING

Underground and above ground storage tanks

Septic (on-site sewage disposal) systems Large-capacity septic systems should be included under

wastewater.

Lawn and garden care

10. RECREATION

Recreation activities (other than boating)

 Golf courses

Surface water recreation areas

 Body contact recreation areas

 Recreational boating areas

11. OTHER MAJOR FACILITIES

Military installations

Federal facilities

Utilities/powerplants

Hospitals

Laboratories Includes research labs, private biomedical labs, and national

labs.

Cemeteries and mortuaries

12. MISC. ENVIRONMENTAL THREATS

Natural sources (e.g., arsenic, radon, wildlife)

Atmospheric Deposition
48

Percent of CWSs or SWAs for CWSs with 

Source Water Protection Strategies In Place and Being Implemented

State: 

Level of Implementation Strategy in Place and Being

Implemented

Substantial Strategy

Implementation

(Columns or rows do not need to add to 100%)

CWS/SWA

for CWS 

Population CWS/SWA

for CWS

Population 

Ground water-based

Surface water-based

Total 

Percent Change in CWSs or SWAs for CWSs Achieving 

Substantial Implementation of Source Water Protection Strategies

State: 

Substantial Strategy Implementation

CWS/SWA for CWS Population 

State total (current year)

Percent change*

current year - previous year

first year

* EPA will calculate the percent change

based on the previous and first years’ data

reported by the state.
49

Appendix IV–Definition of Substantial Implementation of a SWP

Strategy

Note: this is identical text to that presented under Measure 3.2 in Part B.

Substantial implementation is occurring when the state determines: for each CWS (and

related population), strategic protection actions have been or are being taken to appropriately

address state-identified significant sources of contamination, and possibly other concerns in a

source water assessment, taking into consideration the sensitivity of the source water to

contamination.

Explanatory Definitions for Concepts in the Definition of Substantial Implementation:

1. “State determines.” The state decides, working with CWSs and their communities, when a

CWS, separately or as a network or group, has achieved substantial implementation of a SWP

strategy.

2. “Strategic protection actions have been or are being taken to appropriately address.” 

Strategic protection actions for CWSs are based on relevant SWP strategies. Actions may

reflect implementation of a WHP plan, a local watershed plan that includes SWP, or a source

water management control system or plan designed to reduce risks as detailed in a source

water assessment, possibly with specific action indicators in the control system or plan. States

may choose to determine a tailored set of minimum prevention actions, detailed in a publicly

released document developed through a public involvement process consistent with state law. 

Specific actions could include, but are not limited to:

C zoning and related land-use measures that prohibit or restrict uses (e.g., by overlay zoning

or related actions);

C state or local health regulations (e.g., sanitary setbacks);

C land acquisition/conservation easements;

C enforceable (i.e., enforceable under state and/or local laws), or voluntary BMPs;

C public outreach, involvement and education programs related to each significant threat;

and/or

C other actions taken under Federal or state statues such as under the Clean Water Act (e.g.,

TMDLs, NPS management).

These appropriate actions may occur for one CWS or multiple CWSs and be: (a) state-wide,

including Federal actions taken within a state; (b) regionally across jurisdictions; or (c) locally.

3. “Identified significant sources of contamination” can be the same as the “significant

potential sources of contamination” defined in a state’s EPA-approved SWAP (see EPA’s

national SWAP guidance of August 6, 1997 on pages 2-15, 2-16, and 2-17). Or the state can

identify, for SWP, a more narrow subset of the significant sources of contamination.

4. “Sensitivity of the source water to contamination.” Whether the hydrology or

hydrogeology provides a natural barrier (e.g., a confined aquifer) that minimizes the risk to

public health directly, rather than, or in addition to, source water strategic protection actions.
50

Appendix V–Acronyms

ASDWA Association of State Drinking Water Administrators

BMP Best Management Practice

CDX Central Data Exchange

CWA Clean Water Act

CWS Community Water System

DWSRF Drinking Water State Revolving Fund

EPA U.S. Environmental Protection Agency

FGDC Federal Geographic Data Committee

GIS Geographic Information System

GWPC Ground Water Protection Council

NCWS Non-Community Water System

NPDES National Pollutant Discharge Elimination System

NPS Non-Point Source

NRWQC Nationally Recommended Water Quality Criteria

OGWDW Office of Ground Water and Drinking Water

OPP Office of Pesticide Programs

ORD Office of Research and Development

OSCP Office of Science Coordination and Policy

OSW Office of Solid Waste

OUST Office of Underground Storage Tanks

OW Office of Water

PAMs Program Activity Measures

PWS Public Water System

PWSS Public Water Supply Supervision

RDBMS Relational Database Management System

SDWA Safe Drinking Water Act

SDWIS Safe Drinking Water Information System

SWA Source Water Area

SWAP Source Water Assessment Program

SWP Source Water Protection

TMDL Total Maximum Daily Load

UIC Underground Injection Control

USDA U.S. Department of Agriculture

USGS U.S. Geological Survey

UST Underground Storage Tank

XML Extensible Markup Language

 EPA-816-R-05-001

 March, 2005